The US Department of Justice (DOJ) declined to prosecute Liberty Mutual after the insurer voluntarily self-disclosed misconduct....more
On June 9, Deputy US Attorney General Todd Blanche issued a memorandum outlining new guidelines for the enforcement of the Foreign Corrupt Practices Act (FCPA)....more
On May 12, Matthew R. Galeotti, the head of the US Department of Justice’s (DOJ) Criminal Division, announced a new white collar enforcement plan, outlined changes to the Corporate Enforcement and Voluntary Disclosure Policy,...more
On April 2, California Attorney General (AG) Rob Bonta issued an alert reminding businesses operating in California that it is illegal to violate the Foreign Corrupt Practices Act (FCPA)....more
4/10/2025
/ Anti-Corruption ,
Bribery ,
California ,
Compliance ,
Corporate Governance ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Regulatory Requirements ,
State Attorneys General ,
Unfair Competition Law (UCL)
Last week, Attorney General Pamela Bondi issued 14 memoranda outlining new enforcement priorities at the US Department of Justice (DOJ). Notably, DOJ resources will shift away from the Foreign Corrupt Practices Act (FCPA) and...more
2/11/2025
/ Anti-Corruption ,
Attorney General ,
Corporate Governance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Agents Registration Act (FARA) ,
Foreign Corrupt Practices Act (FCPA) ,
Human Trafficking ,
Regulatory Requirements ,
White Collar Crimes
In December 2023, US Congress passed a landmark anti-bribery law: the Foreign Extortion Prevention Act (FEPA). FEPA was designed to supplement the Foreign Corrupt Practices Act (FCPA) and expand liability to foreign...more
DOJ Launches Corporate Whistleblower Awards Pilot Program -
On August 1, the US Department of Justice (DOJ) announced the details of its new Corporate Whistleblower Awards Pilot Program. According to the DOJ, the...more
8/12/2024
/ Bribery ,
Controlled Substances Act ,
DEA ,
Department of Justice (DOJ) ,
Durable Medical Equipment ,
False Claims Act (FCA) ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Health Insurance ,
Healthcare Fraud ,
Internal Reporting ,
Kickbacks ,
Opioid ,
Pilot Programs ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblowers ,
Wire Fraud
On March 7, at the annual American Bar Association (ABA) National Institute on White Collar Crime, US Deputy Attorney General (DAG) Lisa Monaco announced a new whistleblower program that will provide financial rewards to...more
3/19/2024
/ Attorney General ,
CFTC ,
Corporate Crimes ,
Corporate Governance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Pilot Programs ,
Regulatory Agenda ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
This week, SAP SE (SAP), the German-based software company, agreed to pay over $200 million to resolve investigations by the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC) into violations of...more
1/15/2024
/ Bribery ,
Clawbacks ,
Compliance ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Due Diligence ,
Ethics ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Instant Messaging Apps ,
Policies and Procedures ,
Political Contributions ,
Remediation ,
Risk Assessment ,
SAP SE ,
Securities and Exchange Commission (SEC) ,
Settlement
On December 21 President Biden signed the Foreign Extortion Prevention Act (FEPA) as part of the Fiscal Year 2024 National Defense Authorization Act. The legislation addresses a perceived gap in the Foreign Corrupt Practices...more
12/28/2023
/ Anti-Corruption ,
Bribery ,
Compliance ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Due Diligence ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Investigations ,
NDAA ,
Policies and Procedures ,
Risk Assessment ,
Securities and Exchange Commission (SEC)
Recent guidance from the US Department of Justice (DOJ) reflects its continued focus on corporate compensation structures to promote compliance. In the past few months, the DOJ has entered into settlement agreements that...more
11/15/2023
/ Anti-Corruption ,
Clawbacks ,
Compensation ,
Compliance ,
Corporate Misconduct ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement ,
Foreign Corrupt Practices Act (FCPA) ,
Incentives ,
Self-Disclosure Requirements ,
Settlement
On October 4, Deputy Attorney General Lisa O. Monaco addressed the Society of Corporate Compliance and Ethics and announced a new Department-wide Mergers & Acquisition (M&A) Safe Harbor policy. According to the new policy,...more
10/17/2023
/ Acquisitions ,
Anti-Corruption ,
Compliance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Due Diligence ,
Foreign Corrupt Practices Act (FCPA) ,
Mergers ,
Safe Harbors ,
Self-Disclosure Requirements
Supreme Court to Hear US Government in FCA Scienter Oral Argument -
On March 20, 2023, the US Supreme Court agreed to allow the federal government to participate in oral argument in the Supreme Court’s review of the...more
3/27/2023
/ Bribery ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Foreign Corrupt Practices Act (FCPA) ,
Generic Drugs ,
Insurance Fraud ,
Medicaid ,
Medicare ,
Oral Argument ,
Scienter ,
SCOTUS ,
Securities and Exchange Commission (SEC)
Court Reinstates Life Insurance Company's Fraud Claims Over Defunct Laboratory -
A New Jersey state appeals court reinstated Aetna Life Insurance Company’s (Aetna) fraud claims against the minority owners of the now defunct...more
10/18/2021
/ Aetna ,
Bribery ,
Criminal Conspiracy ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Hemp Related Businesses ,
Insurance Fraud ,
Kickbacks ,
Life Insurance ,
Popular ,
Securities and Exchange Commission (SEC) ,
UFTA